This policy establishes a structured framework for the initial use of cryptocurrencies in the Company's licensed gaming operations. Recognizing the regulatory responsibilities associated with virtual assets, this document reflects our commitment to managing crypto-related risks responsibly and transparently from the outset.
Cryptocurrency functionality is being introduced in a limited and controlled manner, supported by strict compliance procedures, customer identity checks, and the use of regulated third-party crypto service providers. The scope of this policy and related procedures will expand as operations evolve.
The Company adheres to all legal obligations applicable under the Curaсao gaming and financial compliance regime, including:
The Company is prepared to cooperate with the FIU Curaсao for reporting any unusual or suspicious crypto-related activity and considers AML/CFT compliance a core operational principle.
At this stage, the use of cryptocurrencies is limited to:
The Company does not engage in speculative crypto trading or long-term holding of cryptocurrencies on its balance sheet.
To minimize risk, only the below cryptocurrencies are accepted:
No privacy-focused coins (e.g., Monero, Zcash, Dash) are allowed due to high anonymity risks.
All supported cryptocurrencies are subject to ongoing review. Any addition of new assets requires a compliance-led risk assessment.
Cryptocurrency transactions are permitted once the customer has successfully completed KYC verification, which includes few or all of the below listed documentation/ information and might not be limited to (as the case may be)
The platform might restrict crypto access until the full identity of the user has been confirmed in line with applicable compliance standards.
To manage exposure, the following thresholds apply to cryptocurrency activity:
| Tier | Verification Required | Monthly Limit (EUR) |
|---|---|---|
| 1 | ID/passport | Up to €1,000 |
| 2 | ID/passport+ Proof of Address | €1,000 – €10,000 |
| 3 | Enhanced Due Diligence | €10,000+ |
Higher-volume users must provide Source of Funds (SoF) and may be subject to ongoing monitoring or temporary restrictions.
The Company uses external tools (e.g., via its crypto payment provider) to ensure wallet addresses are screened before transactions are processed. Wallets are checked for:
Crypto assets received are not stored long-term by the Company. All transactions shall be processed through regulated third-party crypto payment service providers (PSPs) that offer:
The Compliance Officer performs routine reviews of all crypto-related transactions using:
Any unusual activity (e.g., rapid deposits/withdrawals, behavioral anomalies) is investigated and documented. Compliance reports are prepared when feasible and to the extent applicable for internal review.
All relevant personnel are trained on the key risks associated with cryptocurrencies and the controls in place. Training includes:
Annual refresher sessions will be implemented, and training records shall be kept for auditing purposes.
This policy will be formally reviewed:
The Company commits to adapting this policy as the crypto program matures and additional tools or features are integrated.
We confirm that this policy is enforced across all relevant departments and reflects our current operational scope and compliance strategy. It is designed to meet Curaсao’s legal requirements for AML/CFT risk management in relation to virtual assets.
We will update this policy and notify relevant authorities in case of major procedural changes or risk findings.